Using Monitoring Data to Transform Rules into Opportunities.

By Michael Corvese

Cement producers – especially those operating in the United States and Europe – are subject to a broad range of environmental regulation. In September 2015, U.S. cement producers will face a new series of U.S. Environmental Protection Agency (EPA) regulations, which includes emissions limits and maximum achievable control technology (MACT) requirements, comes into effect.

While most of these rules may only apply to U.S. producers, many other nations (particularly China) look to the EPA for guidance on their own emissions control programs. It’s likely, therefore, that other countries will eventually adopt similar regulation in the future – a trend that’s already developing in parts of Latin America.

Many cement producers – most notably those that belong to the World Business Council for Sustainable Development (WBCSD) Cement Sustainability Initiative (CSI) – are taking a proactive approach to managing their environmental impact, but many others struggle to balance regulatory compliance with continuing profitability.

Despite these struggles, however, many in the industry, including CSI, believe that sustainable cement production is possible. While emissions monitoring practices required to meet EPA cement MACT standards can be challenging, they also provide a wealth of data that can drive greater efficiencies across longstanding processes that would likely change very little without external pressure.

Change is always difficult for industry, especially when it’s driven by regulatory forces. But disruption often creates opportunity for new leaders to emerge, and compliance with new standards such as MACT are no exception. Truly innovative companies see beyond the challenges posed by new regulations and look for ways to capitalize on change.

Innovation and Regulation: The History

The Clean Air Act of 1970 was a watershed for U.S. industry, and cement producers were not immune to the massive and difficult disruption. Five of the six criteria pollutants covered by the act – sulfur dioxide (SO2), nitrogen oxides (NOx), carbon monoxide (CO), particulate matter (PM) and lead (Pb) – apply to cement producers. Requirements to measure and mitigate these pollutants was – and continues to be – a costly burden on industry.

In the hopes of alleviating some of this burden, many cement producers actively participated in industry dialogue between regulators, monitoring equipment manufacturers and other stakeholders as the regulatory process unfolded. Without this dialogue, it’s likely that today it would be even costlier and more disruptive to meet the requirement of the act.

One example is stack emissions. Monitoring was once done by continuously measuring the opacity of stack gas, but today the industry relies on continuous emissions monitoring systems (CEMS) that use advanced monitoring techniques such as tapered element oscillating microbalance (TEOM) or light-scattering technologies. Producers that have replaced opacity-based systems with CEMS have reduced related compliance costs significantly and increased the accuracy of their reporting data.

Data generated for compliance also have value beyond regulatory reporting – some innovative cement producers have used data to identify efficiency gaps and improve productivity. A plant in Florida, for example, used data from its mercury monitoring system to redesign its ash handling system and reduce overall mercury emissions. Other examples include using instrument data to make combustion systems more efficient, an especially important innovation for plants that run a highly variable fuel such as used tires.

Partnering with Monitoring Instrument Producers

If regulation is to lead to opportunity, producers must extract greater value from the data that monitoring instruments generate. It’s possible, for example, to use data generated for regulatory reporting to diagnose flaws or inefficiencies in production processes: a producer could conceivably discover a connection between a stack gas anomaly and a process error, saving hundreds of thousands of dollars. It’s unlikely that insight would surface without the rigorous analysis of data.

Surfacing insights from data is certainly part of a monitoring instrument manufacturer’s responsibility to the customer. We’ve worked – and continue to work – closely with EPA to not only understand the requirements of new regulations, such as those that take effect in September 2015, but also to design instruments that provide insights that extend beyond compliance.

Instruments are a means to generate data and, if designed properly, those same data have real value in making production more efficient and profitable. But this can only happen if the data are used effectively as part of ongoing production process review, and not just for reporting.

Monitoring Around the World

The EPA is often a model for other countries looking to design environmental regulations. China’s Ministry of Environmental Protection (MEP), for example, has worked closely with EPA for decades. Given China’s influence in cement production – it produced more than half the total global output of cement in 2013 – the entire industry should follow its policy-making with interest. If Chinese cement producers are adopting U.S.-style measurement and control technologies, it’s likely they’re also exploring ways to use data more effectively.

Any company that produces cement in multiple countries would be wise to consider MACT as more than simply a U.S. regulation. Given the influence of EPA globally, it’s likely that producers will see MACT-like requirements outside the U.S. in the coming years. Preparing now – and building monitoring and data analysis capabilities into all processes, regardless of country of origin – is smart business.

Turning Regulation into Opportunity

Regulation is never welcome. Yet history shows that many of the new technologies, processes and practices that arise from compliance can have a net positive affect. Benefits are not given, however; they must be earned through active participation in the regulatory process and making investments in innovation that go beyond just what’s required.

Regulators do, in fact, rely on voluntary, industry-led sustainability efforts as a cornerstone of their regulatory guidelines. CSI, for example, issued its Agenda for Action in 2002, well before EPA designed its new set of regulations. The Agenda for Action included guidelines for managing airborne emissions and selecting a CEMS.

Complying with what’s coming in September 2015 will be a challenge for many, and we’re already well down the road in this particular regulatory episode. But my colleagues and I have seen this process unfold from the beginning, and let me assure you that there’s room here to turn compliance into opportunity.

The first step, however, is to embrace the data and recognize its proven potential to drive greater production efficiency. And driving efficiency is, after all, the purest form of innovation.

Final Amendments to Air Toxics Standards For Portland Cement Manufacturing

In response to a federal court decision, petitions for reconsideration and technical information received after final rules were issued in 2010, the U.S. Environmental Protection Agency (EPA) finalized amendments to the agency’s air toxics rules for portland cement manufacturing. The amended rule will maintain dramatic reductions of mercury, acid gases, particulate matter and total hydrocarbons from existing cement kilns across the country, while ensuring that emissions from new kilns remain low.

The final amendments apply to two air emissions rules for the Portland cement industry: air toxics standards and new source performance standards. The final air toxics rule retains emission limits for mercury, acid gases and total hydrocarbons from the 2010 rules, along with retaining requirements that kilns continuously monitor compliance with limits for mercury, total hydrocarbons and particulate matter (PM).

The air toxics rule also adjusts the way cement kilns continuously monitor PM emissions, and adjusts emissions limits for PM and organic air toxics. Existing kilns must comply with the standards by Sept. 9, 2015, and if needed, may request an additional year. EPA is making conforming changes to the PM limits in the New Source Performance Standards (NSPS) for new cement kilns.

The rule is expected to significantly reduce pollution from Portland cement manufacturing over 2010 levels when fully implemented, cutting emissions of mercury by 93 percent, hydrochloric acid by 96 percent, PM by 91 percent, and total hydrocarbons by 82 percent.

The revised rule will maintain important health benefits associated with reducing mercury, acid gases and particulate matter while reducing the cost of compliance. EPA estimates that cement kilns will have to spend $52 million less to implement requirements in the revised rule than the 2010 rule.

In developing the emissions limits for the air toxics rule, EPA excluded data from cement kilns that burn non-hazardous solid waste. Those kilns are subject to another rule, the emission standards for Commercial/Industrial Solid Waste Incinerators.

Requirements in the final rules:

The final rules change the monitoring method that facilities use to demonstrate compliance with emissions limits for PM, and make change to the PM emission limits that are necessary as a result.

EPA made these changes based on new real-world technical information that indicated PM emissions could not be reliably measured using the monitoring requirements EPA had required in the 2010 rule.

The revised monitoring method requires kilns to monitor continuously to demonstrate compliance with the PM limits.

The amendments also:

Change the compliance date for existing kilns under the air toxics standards to Sept. 9, 2015. Facilities may request an additional year, if needed. EPA is changing the compliance date because the rule revisions make it necessary for the cement industry to reassess its emission control strategies.

Some facilities are expected to choose different emission controls to meet the revised requirements.

Allow better-performing kilns greater flexibility in meeting the daily operating limits that facilities use to demonstrate continuous compliance. This flexibility applies only to those facilities with PM or organic air toxic emissions that remain below 75 percent of the emission limits in the final rule.

Treat coal mills that use kiln exhaust as a part of the cement kiln. This means emissions from coal mills are included when determining if a kiln is meeting emission limits.

Revise the open clinker pile standards from the 2010 final rule by allowing facilities to choose from a list of work practices to control fugitive emissions. The work practices would apply to any open clinker piles, regardless of the quantity of clinker or the length of time that the clinker pile exists. Facilities must meet the clinker pile standards within one year after the final rule is published in the Federal Register. Accidental spills of clinker, which are not considered open clinker piles, must be cleaned up within three days.

Change the alternative emission limit for organic air toxics; kilns may meet this limit in lieu of meeting a limit for total hydrocarbons.

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About Cement Americas

Cement Americas brings focus to issues affecting cementitious materials suppliers and is a bi-monthly magazine from the publishers of Rock Products. Despite the continued depressed condition of both the U.S. economy and construction activity, gains are being seen in cement consumption in the coming years. Read More